Expert Analysis

In this exclusive op-ed piece for International Tax Review, Chris Lenon, former head of tax for Rio Tinto and an expert witness to the Independent Commission for the Reform of International Corporate Taxation (ICRICT), argues that a focus on incentives and ultra low or no tax jurisdictions should be policy makers’ priority, rather than ideas included in the commission’s report, such as allocation.

After spending 15 years in-house, Ben Henton last month joined BDO as a transfer pricing director. He returns to the UK from Asia after four years working at HSBC and DBS Bank in Hong Kong and Singapore. Here, he addresses operational risk challenges in transfer pricing (TP) from an in-house perspective, going beyond technical TP legislation and guidelines.

A turbulent year for the energy sector has seen oil prices decreasing by more than half from June 2014 to the beginning of 2015 and brent crude oil dipping below $50 a barrel for the first time since May 2009. This volatility has caused longer term, widespread repercussions across the industry. Jimmie van der Zwaan from Taxand Netherlands looks at some of the consequences impacting the sector, including an increase in M&A activity, tax concessions instigated by governments and major oil companies announcing ravaged profits - and this is before considering the gathering momentum of the OECD's initiatives to tackle base erosion and profit shifting (BEPS) in international tax planning.

Jess Williams, Jimmy Man, and Olivier Hody of Deloitte explain how tax can be elevated from a post-close support function to a value-realisation tool in M&A transactions through quick wins and longer-term actions

Deloitte pillar two experts Chad Hungerford and Alison Lobb share their insights on the latest developments and practical issues that are emerging – and what may lie ahead

Dave Yaros, tax principal, Deloitte Tax LLP

Several South Korean transfer pricing cases have established clearer judicial standards emphasising robust comparability analysis and stronger functional and economic evidence. Yulchon tax partners provide practical insights for navigating the heightened requirements

Ichwan Sukardi and T Qivi Hady Daholi of RSM Indonesia examine how geopolitical conflict and economic volatility are reshaping transfer pricing risk and enforcement, with a particular focus on Southeast Asia and Indonesia

Monika Bieri and Daniel Schönenberger of Tax Partner use a Swiss lens to examine how workforce mobility is reshaping transfer pricing models, and why the location of key decision‑makers is becoming a critical tax risk

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe examine a recent decision concerning the transfer pricing treatment of non-remunerated intra-group guarantees, focusing on economic substance, legal form, and group-level business justifications

The key changes under Budget 2025 and the outlook for 2026 raise several areas of heightened focus for taxpayers, say Matthew Kraemer, Adam N Unick, and Justin Ng of McCarthy Tétrault

The Tiger Global Supreme Court ruling weakens the status of tax residency certificates under tax treaties and increases substance‑based scrutiny, say S Vasudevan, Bharathi Krishnaprasad, and Krishna Laasya V of Lakshmikumaran & Sridharan